sale or exchange of the partnership interest of the distributee partner. (b) PartnershipsNo gain or loss shall be recognized to a partnership on a distribution to a partner of property, including money. (c) Treatment of marketable securities (1) In generalFor purposes of subsection (a)(1) and

(a) Amount of creditFor purposes of section 38, the amount of the empowerment zone employment credit determined under this section with respect to any employer for any taxable year is the applicable percentage of the qualified zone wages paid or incurred during the calendar year which ends with or within such taxable year.

prepared by a tax return preparer shall bear such identifying number for securing proper identification of such preparer, his employer, or both, as may be prescribed. For purposes of this paragraph, the terms "return" and "claim for refund" have the respective meanings given to such terms by section 6696(e). For purposes of paragraphs (1), (2), and (3), the identifying

§1.167(f)-1 for rules which permit a reduction in the amount of salvage value to be taken into account for certain personal property acquired after October 16, 1962. See also paragraph (c) of this section for definition of salvage. The allowance shall not reflect amounts representing a mere reduction in market value. See section 179 and

(a) In general. Any person who fails or refuses to submit to a real estate investment trust the written statements required under §1.857-8 to be demanded by such trust from its shareholders of record shall submit at the time he files his income tax return for his taxable year which ends with, or includes, the last day of the

(a)-(e)(3) [Reserved]. For further information, see §1.6662-5(a) through (e)(3). (e) (4) Tests related to section 482—(i) Substantial valuation misstatement. There is a substantial valuation misstatement if there is a

provisions in this part, for any one of the following purposes: (a) Export, as authorized under 26 U.S.C. 5214(a)(4); (b) Transfer to customs manufacturing bonded warehouses, as authorized under 19 U.S.C. 1311;

corporation, estate, or trust) for each taxable year beginning after December 31, 2012, a tax equal to 0.9 percent of the self-employment income for such taxable year which is in excess of— (i) in the case of a joint return, $250,000, (ii) in the case of a married taxpayer (as defined in section 7703) filing a separate return, ½ of

Question 1: For purposes of section 706(d), how is an otherwise deductible amount that is deferred under section 267(a)(2) treated? Answer 1: In the year the deduction is allowed, the deduction will constitute an allocable cash basis item under section 706(d)(2)(B)(iv). (Secs. 267(f)(2)(B), 706(d)(2)(B)(iv

such property were sold to the distributee at its fair market value. (2) Treatment of liabilitiesRules similar to the rules of section 336(b) shall apply for purposes of this subsection. (3) Special rule for certain distributions of partnership or trust interestsIf the property distributed consists of

(a) Payments made outside the United States for prepaid ordersIf the payment upon which tax is imposed by section 4261 is made outside the United States for a prepaid order, exchange order, or similar order, the person furnishing the initial transportation pursuant to such order shall collect the amount of the tax.

1957, effective July 1, 2008, but inapplicable to taxes imposed for periods before such date. Another prior section 5081, added

real property interest" has the meaning given to such term by section 897(c). (2) Foreign personThe term "foreign person" means any person who is not a United States person. (3) Attribution of ownershipFor purposes of subsection (b)(2)— (A) Interests held

section 662. (d) Effect of renunciation or disclaimerSubsection (a) shall not apply with respect to a power which has been renounced or disclaimed within a reasonable time after the holder of the power first became aware of its existence. (e) Cross referenceFor provision under which beneficiary of trust is

(2) a second corporation (hereinafter in this subsection referred to as "parent") throughout the taxable year owns directly at least 80 percent of the stock of the subsidiary, then, for purposes of applying subsection (d)(2) and section 541 (relating to personal holding company tax) to the subsidiary for the taxable year, there shall be taken into